Rule G-14 Real-Time Transaction Reporting Update

This notice discusses several subjects relating to the accurate and timely reporting of transactions to the MSRB’s Real-time Transaction Reporting System (RTRS), including minor changes in RTRS specifications for certain submission and error codes.  It also contains questions and answers about transaction reporting procedures in several special situations.  The notice will become part of the RTRS Users Manual and will be available to dealers on the “RTRS Users Manual” section of the MSRB Web site, www.msrb.org, in the “Real-Time Transaction Reporting” section.

INTRODUCTION

On January 31, 2005, amendments to Rule G-12(f)(i) on inter-dealer comparison and Rule G-14 on transaction reporting became fully effective.[1]  With a few exceptions, these rules now require dealers to submit trade records for comparison and transaction reporting within 15 minutes of the time of trade execution. The MSRB is aware that dealers have expended considerable effort to modify internal trade processing systems and procedures in order to comply with the new requirements. These efforts have been critical to what has been thus far a successful transition to real-time trade reporting. The MSRB is confident that the market will benefit from additional price transparency provided by real-time transaction reporting.

Although the industry has completed most of the major systems changes necessary for real-time transaction reporting, continuing efforts are necessary to ensure that the goal of real-time transparency can be fully accomplished.  The first six months of RTRS operation have provided an opportunity for the MSRB to identify areas where further efforts are needed, to provide guidance to dealers in these areas, and to provide additional tools within RTRS to assist dealers in meeting transaction reporting requirements. In June 2005, the revised RTRS Web browser was implemented, providing dealers with an improved ability to monitor and react to transaction reporting issues on a real-time basis.[2]  The MSRB has sponsored several industry seminars and conferences to help educate dealers on use of this tool.[3]  The MSRB also has made available a new monthly “report card” which allows dealers to compare their real-time transaction reporting performance with industry averages. [4]

This notice contains important information about additional MSRB efforts to improve RTRS functionality and real-time transaction reporting. It describes several changes in the "error codes" that RTRS returns to a dealer when certain conditions are found on the dealer's trade report. It also announces revisions in the "Special Condition Indicator" used by dealers to mark a trade report as containing a non-market price or to indicate the existence of certain special conditions. The new trade reporting procedures relating to these system changes generally will become effective on November 15, 2005. However, guidance also is provided on the use of existing error and indicator codes and this guidance is effective immediately. Finally, the notice compiles a list of previous guidance on RTRS transaction reporting procedures and contains reminders on the correct methods for reporting inter-dealer trade reversals, extended settlement trades and other special situations.

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SPECIAL CONDITION INDICATORS TO REPORT TRANSACTIONS WITH PRICES AWAY FROM THE MARKET

The RTRS “Special Condition Indicator” is used by reporting dealers to indicate a variety of special conditions concerning price transparency and transaction reporting.  (The Special Condition Indicator was previously known as the Special Price Reason Code.)  As initially implemented, RTRS included  Special Condition Indicators M200, M210, M220, and M230 (“M2nn indicators”). [5]  M2nn indicators are used to report that a transaction price is one where an unusual settlement cycle has affected the reported price so that it is different than the market price of the security. 

These transaction reports are required for surveillance reasons, but are not published. [6]  To further clarify the conditions under which these indicators are used, the MSRB is providing the accompanying description of the M2nn indicator series and describing its use.  Also, the MSRB is adding an indicator series (M9nn, described below) to identify transactions whose price is away from the market for other reasons.  Finally, the MSRB is announcing its plan to introduce a new Special Condition Indicator to distinguish prices arising from conditional trading commitments from other new-issue prices.

Use of the Existing Indicators 

Dealers currently are required to use an M2nn indicator (M200, M210, M220, or M230) only when two conditions both exist:

•  The parties to the transaction agree to significantly deviate from the normal settlement cycle of the trade (T+3 for regular way trades or the first settlement date for when-issued trades) and, as a result,

•  The transaction is effected at a price that substantially differs from the market price.[7]

The existing description of the M2nn indicators is that the transaction being reported is one where “settlement not RW impacts price.”  To prevent confusion regarding M2nn indicators, the MSRB has rephrased the accompanying description to denote that the transaction is “Away from market price (extraordinary settlement).”  The MSRB reminds dealers that an M2nn indicator should be used only when the price of the transaction is away from the market price because settlement is not regular way.  It should not be used for extended settlement trades or cash/next-day trades that are at the market price, nor should it be used routinely for trades done on a when-issued basis.  For when-issued trades, an M2nn indicator should be used only when the price is away from the market price because the settlement date is not the issue’s initial settlement date.  The same rules will apply to any indicator in the M2nn series  that may be created in the future.

As noted above, RTRS does not publicly disseminate a trade that is reported with an M2nn indicator, but such reports are available to regulatory agencies for market surveillance and inspection purposes.  To ensure the transparency of market prices, it is particularly important that dealers use M2nn indicators only when reporting transactions with prices away from the market price.  Incorrect use of M2nn indicators will impair transparency and is a violation of Rule G-14.

Additional Indicator M9nn

In RTRS Version 1.2.1, the MSRB is adding indicators M900, M910, M920 and M930 (“M9nn indicators”).  M9nn indicators will be used to report transactions away from the market price for a reason that is not covered by an M2nn indicator, or for more than one reason.  The same rule will apply to any indicator in the M9nn format that may be created in the future. 

RTRS will not publicly disseminate M9nn transactions and, as for M2nn, proper use of M9nn is particularly important.  Use of M9nn indicators is required beginning on November 15, 2005.  Although dealers may use M9nn indicators before that time, failure to do so on or after November 15, 2005 will constitute a violation of Rule G-14.

Addition of the M9nn indicators to those indicators already in the Specifications results in the following complete set of Special Condition Indicators (new or changed material in italics):

Special Condition Indicator[8]	Condition
M010	Not special price – 3 hour report deadline (not in security master)
M020	Traded at list price – EOD report (list price trade by syndicate)
M030	Not special price – EOD report (< 9 months in effective maturity)[9]
M100	Traded flat – 15 minute report deadline
M110	Traded flat – 3 hour report deadline (not in security master)
M120	Traded flat – EOD report (list price trade by syndicate)
M130	Traded flat – EOD report (< 9 months in effective maturity)
M200	Away from market price (extraordinary settlement) – 15 minute report deadline
M210	Away from market price (extraordinary settlement) – 3 hour report deadline (not in security master)
M220	Away from market price (extraordinary settlement) – EOD report (list price trade by syndicate)
M230	Away from market price (extraordinary settlement) – EOD report (< 9 months in effective maturity)
M900	Away from market price (other reason) – 15 minute report deadline
M910	Away from market price (other reason) – 3 hour report deadline (not in security master)
M920	Away from market price (other reason) – EOD report (list price trade by syndicate)
M930	Away from market price (other reason) – EOD report (< 9 months in effective maturity)

 

Plan for New Indicator to Distinguish Conditional Trading Commitments

In a notice published in 2004, the MSRB discussed apparent anomalies in reported trade data in some new issue offerings where conditional trading commitments have been made prior to the time of formal award.[10]  Under some conditions, the first prices reported for an issue may not be reliable indicators of current market conditions.  The MSRB stated that it was considering whether it would require an additional indicator on the transaction report of new issue trades that are executed on the basis of a conditional trading commitment.  The MSRB plans to require an additional Special Condition Indicator for these trades.  A future notice will describe the indicator in detail and explain how it will be used in price transparency reports.

FEEDBACK TO DEALERS REGARDING ERRORS IN TRANSACTION REPORTS

RTRS responds to each dealer submission of a trade report by sending feedback to the dealer showing either that the submission was satisfactory or that it contained errors.  A “Questionable” message indicates that RTRS has found an exceptional condition that may be an error.  As stated in section 2.9 of the Specifications, after receiving such a message a dealer should examine the trade data and, if necessary, its processing system and procedures to determine why the trade report was deemed questionable by RTRS.[11]  “Questionable” conditions require dealer attention and any actual error must be corrected by submission of correct data. However, a "Questionable" error does not necessarily mean that the trade report was in error.  If the dealer finds that the trade was reported correctly, it does not have to respond to the error message.

This section of the notice clarifies the circumstances when three Questionable error messages may be returned to the dealer on a valid trade submission and discusses known limitations in two of the messages.  This section also announces that two error codes are being added and that the code value or message of three other error codes is  being changed for greater clarity.  It also describes special reports for dealers, recently provided by the MSRB, that will aid in dealer review of inter-dealer trades that have discrepancies between the reports submitted by the two parties to the trade.

Clarification of Error Codes Q116, Q141 and Q311 on Valid Trade Submissions

Error codes Q116 and Q141 indicate possible errors in calculations reported in trade submissions, and error code Q311 indicates that a trade has been reported in a CUSIP number for which RTRS has no descriptive data for price verification.  The MSRB is providing guidance to dealers for responding to these error messages, which are returned in special situations.

Q116 – “QUEST Dollar price calculated to pre-refunded date and lower call date exists.”  The MSRB has learned that RTRS in some cases may be erroneously returning this code to transactions in pre-refunded bonds where the submission includes yield properly calculated to the pre-refunding date and the bond has no exercisable calls prior to the pre-refunded date.  Dealers that have received erroneously applied Q116 messages should ensure that their calculations are correct, but are not required to take corrective action.  The MSRB is in the process of changing RTRS price-yield calculations to correct this message.  A notice announcing the change will be made in the near future.

Q141 – “QUEST No accrued interest submitted, and trade not shown as having been traded flat.”  The MSRB has learned that RTRS may be erroneously returning this code to certain when-issued submissions reported with dollar price or yield and reported without accrued interest, as well as trades submitted when settlement date is the same as dated date.  Dealers receiving erroneously applied Q141 messages should review the trade report to ensure that it is correct, but are not required to take corrective action.  The MSRB is in the process of changing RTRS accrued interest editing methods to correct this message.  A notice announcing the change will be made in the near future.

Q311 – “QUEST Dollar price cannot be verified.  No CUSIP data available to RTRS.”  As noted in the Specifications (Appendix B.1), Q311 applies to trades with CUSIP numbers for which RTRS has not received securities description information within 60 days from the time the trade is reported to RTRS.  This code and message have been in the Specifications but have not been returned to dealers.  Q311 and its message will be sent to dealers beginning on November 15, 2005.  Dealers receiving Q311 should review the trade report to ensure it is correct and in particular should check to see if the security traded was a municipal security with a CUSIP number assigned by the CUSIP Service Bureau of Standard & Poor’s.  Note that RTRS will send this message 60 days after the trade report is received from the dealer if no information on the CUSIP number has been received by the MSRB from its information vendor.

Additions and Changes to Error Codes and Messages

The MSRB is making minor revisions to several error codes to make them more useful to dealers reviewing their submissions of trade reports.  The changes consist of the addition of two error codes, the change of one error message from Unsatisfactory to Questionable, and revisions in the text of two error messages. 

Addition of codes to Specifications.  Two codes and messages are being added to the Specifications in Version 1.2.1.  These provide feedback on reports without par amounts (or where reported par is zero) and reports with invalid Special Condition Indicators.  RTRS has been providing these codes as feedback since implementation, but they were omitted from earlier versions of the Specifications.  The added codes are:

U33D            UNSAT  Par may not be zero
Q55D            QUEST  Invalid special condition code

Code change from unsatisfactory to questionable.  Error code U191 denotes a trade report where the reported yield is greater than the reported dollar price.  The level of this code is being changed from Unsatisfactory (U191) to Questionable (Q191) to recognize that certain trades may legitimately have a yield that exceeds the dollar price.  This change goes into effect on November 15, 2005.  The change is:

Currently:         U191   UNSAT Yield greater than dollar price
Changed to:      Q191   QUEST Yield greater than dollar price

Change in wording of messages.  The wording of two error messages is being changed to make them more self explanatory.  The error codes themselves, and the conditions they denote, are not changing.  These changes go into effect on November 15, 2005.  The changes are:

Currently:         Q06A  QUEST  Reversal number error
Changed to:      Q06A  QUEST  Reversal control number missing or incorrect on
                        your or contraparty report

Currently:         Q55F  QUEST  Special price code inconsistent with trade history
Changed to:      Q55F   QUEST Special condition indicator inconsistent with trade
                        history

Feedback on Inter-Dealer Trade Discrepancies

Dealers have asked the MSRB for clarification about certain RTRS error messages sent when the buy-side and sell-side of an inter-dealer trade submit substantially different information.  These are messages Q19F, “Accrued interest different on buyer and seller sides,” Q22F, “Seller and buyer times of trade differ by more than 15 minutes,” and Q44F, “Contra party you indicated is not the contra party on the matching side.”  RTRS cannot determine from the available data which party’s submission is correct and which incorrect.  In response to these messages, dealers should research why a particular error code was received and correct erroneous data or resolve the discrepancy with the contra party.  To assist in researching why these error codes were applied, the MSRB provides the “Discrepancy Error Code Report,” which provides information about contra party submissions.  The report displays trade reports that received error codes Q19F, Q22F and Q44F and shows the information submitted by both parties.  Dealers can access the report via the RTRS Web.[12]

Publication of Specifications Version 1.2.1

On November 15, 2005, the MSRB will publish Version 1.2.1 of the Specifications for Real-time Reporting of Municipal Securities Transactions (“Specifications”).  All error codes and messages are in Appendix B.1 of the Specifications.  This minor revision of Version 1.2 adds the Special Condition Indicator  M9nn series and makes the above changes to error codes and messages.  This version also corrects an inconsistent statement regarding accrued interest.[13]  The Specifications will be available on www.msrb.org.

SUMMARY OF POST-IMPLEMENTATION RTRS ENHANCEMENTS AND REMINDERS

Since RTRS implementation in January 2005, dealers have successfully made the transition from overnight to real-time transaction reporting.  The MSRB will continue to support the industry by providing guidance to dealers based on questions and comments it receives.  Telephone assistance is available from the Transaction Reporting Assistants and other MSRB staff.  The following MSRB Notices on www.msrb.org summarize post-implementation changes and reminders of which dealers should be aware:

•        “Real-time Compliance Reports are Available,” Notice 2005-13 (March 22, 2005)

•        “RTRS Web Enhancements and New Reports Implemented June 14, 2005,” Notice 2005-35 (June 13, 2005)

•        “RTRS Update and Review of Enhancements to RTRS Web – Educational Conference Calls,” Notice 2005-38 (July 18, 2005)

The MSRB has also recently published the following reminder notices:

•        “Reminder Regarding Modification and Cancellation of Transaction Reports,” Notice 2005-13 (March 2, 2005)

•        “Notice on Comparison of Inter-Dealer Deliveries that Do Not Represent Inter-Dealer Transactions – ‘Step Out’ Deliveries:  Rules G-12(f) and G-14,” Notice 2005-22 (April 1, 2005)

QUESTIONS AND ANSWERS ON TRANSACTION REPORTING

            As part of its continuing efforts to provide clarification, the MSRB is adding the following questions and answers to the RTRS Users Manual.[14]  These are reminders to dealers of the transaction reporting requirements in special situations:

• Reporting reversals of inter-dealer transactions

• Reporting the time of trade execution

• Reporting trades with extended deadlines

• Reporting dollar price and commission on agency trades.

Reporting Reversals of Inter-Dealer Transactions

1.

Q         What is a “reversal” of an inter-dealer transaction?

A         Dealers use the Fixed Income Clearing Corporation’s Real-Time Trade Matching (“RTTM”) system both for real-time comparison of inter-dealer transactions and for regulatory reporting of transactions to RTRS.[15]  To offset inter-dealer transactions that have been matched, dealers submit “reversal” transactions into RTTM.  RTTM forwards reversals to the MSRB for regulatory reporting purposes. 

2.

Q         What is the importance of minimizing the number of reversals?

A         RTRS disseminates data about matched inter-dealer trades (and customer trades) in real-time to provide the municipal securities market with transparency.  Since a reversal causes a matched trade to be exactly offset, when RTRS receives the reversal submission it disseminates in real-time an indication that the original matched trade has been “cancelled.”  Between the time the trade is matched and when it is reversed, unreliable transaction data is disseminated to the market.  For this reason, dealers should ensure that the initial report of each trade is accurate and complete, to keep the number of reversals at the lowest possible level.[16]

3.

Q         What are the requirements for submission and regulatory reporting of reversals?

A         Reversals, like other transactions, must be reported correctly.  The buy-side and sell-side reversal submissions reported by the parties to the transaction must match within RTTM.   Further, RTRS requires that dealers submit an identifier that associates the reversal with the transaction being reversed.  Linkage of the reversal transaction and the reversed transaction is important so market participants can be informed that potentially unreliable information has been cancelled and for construction of the “audit trail” of transactions, which is provided by the MSRB to the enforcement agencies. 

4.

Q         How does a dealer satisfy the requirement to associate a reversal with the trade being reversed?

A         To link a reversal and the trade being reversed, dealers submitting a reversal must populate the Reversal Control Number field of the trade input with an identifier of the trade that is being reversed.[17]  Dealers have the option to enter any one of three identifiers to identify the trade being reversed:  the original External Reference Number (Xref), the RTTM Transaction ID number (TID), or the RTTM Match Control Number. 

5.

Q         Must both parties to a reversal identify the trade being reversed?

A         Yes.  Each dealer that is a party to a bilaterally reported trade must enter a Reversal Control Number.[18]  Both parties must identify the same trade to be reversed, even if one dealer enters the trade’s Xref and the other dealer enters its TID or Match Control Number.  Before submitting a reversal, the parties to the reversal should work to ensure that they identify a single trade to be reversed.  Incorrectly reported reversals may prevent RTRS from disseminating the information that the original transaction was “cancelled” and may also impact the audit trail of transactions. 

6.

Q         What feedback does RTRS provide if a reversal is not correctly reported?

A         If a reversal is entered incorrectly, error conditions arise that may prevent RTRS from reversing the trade.  A reversal submission that does not have a Reversal Control Number results in error U06B, “Reversal control number missing.”  Matched reversal submissions that do not both identify the same trade to be reversed cause error Q06A, “Reversal control number missing or incorrect on your or contraparty report,” to be sent.  Both dealers receive message Q06A since RTRS cannot determine unambiguously which trade to reverse.

            RTRS provides two means to see the status and number of reversals.  The G‑12(f)/G‑14 Compliance Data Report or “report card,” which covers a month of trade reports, displays the number of reversals submitted and matched by a clearing dealer, as well as the number of trades that were reversed.  These statistics are in the section, “Changes to Inter-dealer Trades.”  Unequal numbers of reversals and reversed trades indicate either that trades were reversed after the month covered by the report, or that reversals have not unambiguously identified which trade to reverse.[19]  RTRS Web also supports tracking of individual reversals and reversed trades, each of which is denoted by a special symbol on the Search Results and Trade Information screens.  The screens show whether reversal submissions have been matched in RTTM.  Viewing the original transaction will also show whether or not it has been reversed in RTRS.

Time Of Trade Execution

7.

Q         Is the “time of trade execution” considered to be the time that I enter the trade into my internal trade processing system?

A         As defined in Rule G-14 Transaction Reporting Procedures (d)(iii), the time of trade execution is the time at which a contract is formed for the sale or purchase of municipal securities at a set quantity and set price.  Dealers should be aware that trade executions cannot occur in new issues prior to the time of the formal award.  In some situations, inter-dealer trades are executed as a result of one dealer executing an order it holds from another dealer.  In these cases, the dealers will need to come to some agreement on how the dealer providing the executable order will be informed of the time of execution so that its side of the trade can be submitted for trade reporting in a timely manner.  Dealers must report the time of trade execution and not the time the trade data was entered into the internal system, if these two times are different.[20]

Reporting Trades With Extended Deadlines

8.

Q         If a trade is not required to be reported within 15 minutes, must the dealer indicate the applicable deadline?

A         Yes.  The dealer must indicate the applicable deadline when submitting a transaction report, using the third character of the Special Condition Indicator.[21]  RTRS will send message N913, “LATE Trade reported after deadline,” if a submission is received more than 15 minutes after the time of trade and it does not have a Special Condition Indicator with the value 1, 2 or 3 as its third character.

Reporting Dollar Price And Commission On Agency Trades

9.

Q         In reporting an agency trade with a customer, should the reported dollar price include the effect of the commission?

A         No.  The dollar price and the amount of commission, if any, should be reported separately to RTRS, and the effect of commission should not be included in the reported dollar price.[22]  When disseminating a report of a sale to a customer, RTRS converts the commission to the same units as dollar price, adds the commission to the dollar price provided by the dealer, and disseminates the sum as the dollar price of the transaction.  Similarly, when disseminating a purchase, RTRS subtracts the commission from the dollar price provided by the dealer and disseminates the resulting dollar price of the transaction.

EFFECTIVE DATE OF RTRS CHANGES

The RTRS changes described below will become effective on November 15, 2005. These changes will be embodied in Version 1.2.1 of the Specifications for Real-time Reporting of Municipal Securities Transactions ("Specifications").

• Dealers must use Special Condition Indicator M9nn when applicable

• RTRS will begin sending dealers message Q311, regarding securities with no CUSIP data

• Minor revisions will be made to error code/messages U191, Q06A and Q55F

• Version 1.2.1 of RTRS Specifications will be published

The remaining guidance on transaction reporting procedures contained in this notice may be used immediately.

 

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Questions about policies and procedures in this notice may be directed to Jay Jackson, Uniform Practice Assistant, or Larry Lawrence, Policy and Technology Advisor.  Questions about particular transaction submissions may be directed to a Transaction Reporting Assistant.

August 17, 2005